ONLINE GAMBLING ARE WE EXPLOITING THE OPPORTUNITY?

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1 VOLUME 7 NUMBER 2 FALL 2014 ONLINE GAMBLING ARE WE EXPLOITING THE OPPORTUNITY? Changes to UK Internet Gaming Regulations AML: Not Just Another Three- Letter Word A Call for Collaboration

2 MESSAGE FROM THE PRESIDENT With summer coming to an end and another exciting season of gaming events fast approaching, IMGL is looking forward to a multitude of gaming events, conferences and trade shows this season. Of course, our own IMGL Autumn Conference, 5-7 November 2014, which will be taking place in one of the most brilliant cities in Tuscany, Florence, will mark one of the highlights in this year s events calendar. But IMGL and its gaming law experts will also be supporting many other important gaming events around the world this year: New IMGL Master Classes will be held at the Eastern European Gaming Summit in Sofia, Bulgaria (20-21 October 2014) and during the KPMG igaming Summit on the Isle of Man (10-11 November 2014) and many of our members are engaged as speakers at some other major events such as and to name but a few the G2E in Las Vegas (30 September 2 October 2014), the EiG in Berlin (22-23 October) and the MiGS in Malta (11-12 November). In fact, I am delighted to find that there seems to be no leading gaming law conference that does not feature IMGL members as prominent speakers on their panels. The IMGL committees have shown great commitment and sensitivity in selecting the 2014 award winners of the Regulator of the Year-Award. They were selected from a host of qualified proposals. The IMGL wishes to show its appreciation of the successful and widely acclaimed work carried out by these regulators. It is a pleasure to announce that this year the following regulators will be honored: For the Americas: Stephan Martino, Director, Maryland Lottery and Gaming Control Agency, Maryland For Europe: Carlos Hernandez, General Director of the DGOJ, Ministry of Finance and Public Administrations, Spain For the Indian Countries: Thomas Russell, Commissioner, Pokagon Band Gaming Commission, Arkansas For Asia/Australasia: Malcolm Richardson, Director of Compliance and Investigations, Department of Business, Northern Territory Australia You may have noticed that Asia/Australasia has been introduced as a new category. Due to the increasing number of members from the Asian and Australian region and in view of the significant developments of markets and regulation in this part of the world it was high time to do so. Malcolm Richardson will be the first regulator to receive the Regulator of the Year Award for this region. I am particularly happy to introduce yet another new category: the IMGL Lifetime Achievement Award. This award honors experienced regulators for their lifetime achievement and outstanding service in developing and improving regulation and continuously promoting and encouraging debate and an open dialogue among all parties involved. The first award winner is Pete Bernhard, Former Chairman of the Nevada Gaming Commission. The IMGL magazines play an increasing role in shaping gaming law in various jurisdictions. This is due to the fact that they are characterized by an outstanding content and topicality and the specialist expertise of the authors. Things are also moving forward regarding the IMGL world of digital communication. In an ongoing effort to better serve the IMGL members and the gaming community, the IMGL website is undergoing a complete redesign and technology update. This will include introducing e.g. the possibility of creating a personal profile and uploading articles and many other exciting new features. You may witness the launch of our new site on 5 November at the IMGL Autumn Conference in Florence. After the launch I encourage you to get familiar with the site, try out the new features and make this site your site. Hoping to see you at one of our upcoming IMGL events. Joerg Hofmann Publisher Editor Advertising Sales Senior Designer Designer Production Manager Circulation Manager Proudly published by: Publisher Chuck Nervick Editor Sean Moon Chuck Nervick Michael D. Lipton Q.C. Chuck Nervick Annette Carlucci Jennifer Carter Rachel Selbie Gill Daniels IMGL President Joerg Hofmann IMGL Executive Director Melissa Triplett Canadian Gaming Lawyer is published twice a year as a joint venture between Canadian Gaming Business Magazine and the International Masters of Gaming Law (IMGL). For advertising information, Contact Chuck Nervick ext. 227 For editorial information, For editorial information: Contact Michael D. Lipton at Canadian Gaming Business Magazine is owned and published by: 2 CANADIAN GAMING LAWYER MAGAZINE

4 FEATURE BY TONY COLES Changes in British Internet Gambling Regulation and Taxation Back in 2005 the UK introduced a new Gambling Act with the aim of updating the law covering gambling and betting of all kinds and at the same time introducing a modern and forward looking approach. The 2005 Act provided that all gambling would be regulated on the same basis and that the way in which a player actually gambles would not affect its regulation more than is necessary. Gambling on the internet, or by means of any other electronic device, is therefore regulated as remote gambling in, insofar as possible, exactly the same way as gambling at a brick and mortar site ( non-remote gambling). Because remote gambling could, and would, be made available across national boundaries, and because the UK is a Member State within the European Union, the 2005 Act provided that where remote gambling is regulated in another Member State within the European Union ( EU ) or, indeed, another Member State within the European Economic Area ( EEA ), it is permissible for gambling to be made available in Great Britain in exactly the same way as remote gambling regulated by the British Gambling Commission. So under the regime provided for in the 2005 Act internet gambling in Britain has been regulated at its place of supply (the jurisdiction where the operator is based) rather than its place of consumption (where the player sits). And as the 2005 Act is a regulatory and not a tax enactment, and because UK taxation is dealt with under separate provisions, remote gambling operators based outside Great Britain, but elsewhere within the 4 CANADIAN GAMING LAWYER MAGAZINE

5 FEATURE To justify the changes brought into effect by its 2014 Act the UK Government has said that the system introduced in 2005 was flawed and did not properly protect British players. EU/EEA, have only paid the taxes of the Member State in which they are regulated even though many of their players are actually in Britain. At the time it introduced the 2005 Act the British Government put in place a so-called white list. This was thought necessary because, before 2005, many internet gambling operators had organised their business so as to operate from, and thus to be regulated by, one of several jurisdictions which while not part of the UK are associated with it. While the 2005 Act was being implemented arguments were put forward by Alderney, the Isle of Man and Gibraltar that as their own respective regulatory regimes were each proper they should each have the same status as a jurisdiction in the EU/ EEA. These arguments were accepted by the UK Government and the 2005 Act therefore provided that the same principles were to apply to jurisdictions on the so-called white list as to those in the EU/EEA. A procedure was therefore adopted for the UK Government to create this white list and white listed status was eventually granted to Alderney, the Isle of Man, Tasmania and Antigua, Gibraltar itself being already sufficiently associated with the EEA. The 2005 Act, and its operation by the British Gambling Commission has worked reasonably well but the current UK Government (formed following the 2010 General Election by a coalition of the Conservative and Liberal Democrat parties replacing the earlier Labour Party Government) has decided to introduce new arrangements for the regulation of remote gambling for British players. In mid-2011 new legislation was announced to amend the 2005 Act so that all remote gambling operators who deal with British players will need a licence from the British Gambling Commission regardless of where those operators are already licensed. For players in Great Britain an EEA/white list jurisdiction licence will no longer be acceptable with the result that UK licensing is changing to a point of consumption basis. This 2011 announcement of changes in the regulatory regime was accompanied by an announcement that taxation of remote gambling by British players would also change to a point of consumption basis. To achieve these changes in the 2005 Act the UK Parliament has now passed the Gambling (Licensing and Advertising) Act 2014, parts of which have come into force as transitional arrangements, with the remainder coming into effect at the beginning of October. The 2014 Act has extended the territorial application of Section 33 of the 2005 Act so as to require that all remote gambling operators must obtain a licence from the British Gambling Commission if they want to do business with people located in Great Britain. This means that, a UK licence is required if at least one piece of remote gambling equipment used in the provision of facilities by an operator is situated in Great Britain or, even if no such equipment is in the UK, an operator s facilities are capable of being used by players in Britain. The 2014 Act has also abolished the offence of advertising foreign gambling but has extended the territorial scope of advertising unlawful gambling (Section 330 of the 2005 Act) and the regulations controlling the advertising of remote gambling by way of remote communications (Section 328). Although not specifically related to remote gambling, one of the effects of this change is that it may no longer be illegal to advertise in Great Britain non-remote gambling elsewhere in the world, possibly removing the restrictions which, since 2005, have prohibited foreign casinos, for example those in Canada, from advertising in Great Britain. To justify the changes brought into effect by its 2014 Act the UK Government has said that the system introduced in 2005 was flawed and did not properly protect British players. It has advanced detailed reasons in support of the changes but despite this there remains a belief that a main, if not the most important, reason for the 2014 Act is that it will enable the UK Treasury (i.e. the UK Finance Ministry) to tax all remote gambling operators on all revenue which they receive from the participation of British residents. Such a fiscally based reason would be inconsistent with the jurisprudence of the Court of Justice of the European Union (and the UK Government has been cautious in aiming to ensure that its legislation complies in full with UK s commitments as a Member State in the EEA) but if a mere consequence of the changes in the social legislation (i.e. the 2014 Act amending the 2005 Act) is to change the tax regime thus would seem to satisfy the European Court s jurisprudence. The UK Government will thus maintain that the change in the taxation regime which Fall

6 FEATURE is being introduced is not inconsistent with the UK s obligations under its EEA Treaty obligations. Now that the 2014 Act in force, and now that the secondary legislation (principally the Gambling (Licensing and Advertising) Act 2014 (Transitional Provisions) Order 2014) has been published, the British Gambling Commission is implementing the new regime. This implementation includes machinery for those currently licensed in an EU/EEA/white list jurisdiction to have continuation rights so long as they apply by 16th September And even if the Commission has not finally determined an advance application before the 2014 Act comes fully into force in October those licensees holding continuation rights will be issued with a continuation licence which will authorise them to operate in the UK until the outcome of their application is eventually known. But those remote gambling operators who have not been licensed in an EU/EEA/white list jurisdiction, but who nonetheless want to do business with British Players or to advertise in the UK, will need to lodge an entirely new application with the Commission. Indeed operators will be committing an offence in the UK if they do business with British players after 1st October 2014 without a British licence. At the same time as the enactment of the 2014 Act the Gambling Commission has implemented a new compulsory on-line application process. This on-line application aggregates the contents of the IAGR Multi-Jurisdictional Business Form and the British Commission s UK Jurisdiction Rider, although for those EEA/white list applicants applying under the transitional provisions the Commission has identified a smaller subset of questions, the balance of the required information being obtained from the operator s home regulator. There is also a need for relevant key personnel of each licensee to hold a personal licence. The provisions under which the different kinds of personal licences are required, and the machinery for seeking them, are complex and beyond the scope of this article but those doing business in the UK should appreciate that they must prioritise the submission of personal licence application(s) along with the main application itself. To this end the Commission has launched new forms and personal declarations and identified new requirements for those requiring such personal licences. Coincidently the British Gambling Commission has also introduced changes to its Licence Conditions and Codes of Practice (together known as its LCCP ) which attach to all the licences it issues both to remote and to non-remote operators. The LCCP include new provisions for complaints and disputes, new anti-money laundering arrangements, and the requirement for independence from other business operations of the compliance function. The LCCP also address the protection of customer funds and the need to display an operator s licensed status, as well as introducing requirements for the operator to report to the Commission a much extended number of key events. There are also now new conditions specific to poker and other networks and payment processors, as well as an important change requiring all UK licensed operators (obviously greatly extended in number as a consequence of the 2014 Act) to obtain their gambling software only from a holder of a British gambling software operating licence. This important change (which comes into effect on 30 January 2015) has led to much discussion regarding the definition of gambling software. This was originally defined in the 2005 Act as computer software for use in connection with remote gambling although it specifically does not include anything for use solely in connection with a gaming machine. This statutory definition is extremely wide but the Gambling Commission has long since indicated that in their view the definition does not cover software used by non-gambling businesses as well as by gambling businesses, such as general infrastructure or business application software (general Microsoft, or Apple applications for example). But because of the changes introduced in the newly amended LCCP, and because of on-going issues regarding the definition, the Commission in June 2014 issued specific advice that it considers that any software designed for use in connection with remote gambling and which is intended to be used, or is used, by a gambling operator in the provision of its facilities for gambling, to be within the definition. This includes gambling specific applications such as software used in virtual event webpages, virtual event control, bet capture/ matching, settlement, random number generation and the maintenance of those gambling records which show detailed results of games. The Gambling Commission has also issued detailed guidance on which entities in the supply chain for the production of such software need to hold its licence, since it accepts that in many cases many organisations and individuals may be involved, some perhaps peripherally, in creating the final gambling software product used in the operation of a remote gaming site. Readers may well be aware that one of the initiatives which the British Gambling Commission has now introduced has led to much comment worldwide. As part of its updated remote licence application process, the Commission requires details of the jurisdictions from which a licensee derives revenue, including explanations as to the basis on which a licensee operates in a so-called grey market. Specifically the Commission requires B2C applicants to identify markets which make up at least 3% of revenues with an explanation for each jurisdiction as to why the applicant thinks it is not acting unlawfully. And if a licensee has no licence in the relevant jurisdiction the British Commission wants to be told the legal rationale for transacting with players there, and if legal advice has been taken the name of the law firm which gave it. Additionally the Commission has to be informed of those other jurisdictions which a licensee is actively targeting with confirmation 6 CANADIAN GAMING LAWYER MAGAZINE

7 FEATURE that a B2C applicant does not knowingly take business from any jurisdiction in which it is either illegal for the player to play or for the operator to provide services. Similar issues arise for B2B operators with regard to their commercial risk of exposure to grey markets ; put broadly, the Commission requires to understand where a B2B licensee obtains its revenues. Not surprisingly these provisions have generated a degree of uncertainty but it must be understood that the Commission will take a dim view if an operator undertakes business in regulated markets without the necessary licence. The Commission has said that it will not publish a list of jurisdictions in which its licensees must cease to trade but expects them to undertake their own due diligence and put controls on place to ensure that they meet legal requirements around the world. The Commission has emphasised its concern that a licensee may possibly be relying on revenue from a grey /illegal market. The arrangements for the taxation of revenue from British players which is received by licensees operating under the new regime have also been brought into place but separately from the 2014 Act. The necessary fiscal legislation is now enacted with the consequence that, from 1st December 2014, remote gambling operators doing business with players resident in Great Britain will be required to pay British gross profit tax at a rate of 15% on their earnings from British players. It is therefore expected that by the end of 2014 the UK will have completed the implementation of its second attempt at the regulation and taxation of remote gambling, although the Gibraltar Betting and Gaming Association has announced that it has applied to the courts for a judicial review of the changes introduced by the 2014 Act. But whatever the eventual outcome of any such proceedings it is most unlikely that the introduction of the new regulatory and taxation regimes will actually be delayed. CGL Tony Coles is a senior member of Jeffrey Green Russell s Gaming and Betting Department in London. He is well-known in the leisure industry for his specialist knowledge of UK and EU gaming and betting law. He enjoys an international reputation for the strength of his practice. Clients span a range of sizes and sectors and include a number of international household names in the leisure industry. 1. The Gambling Act 2005 was passed into law by the Parliament of the United Kingdom of Great Britain and Northern Ireland. But the Act only has affect in Great Britain (i.e. England, Scotland and Wales). The Province of Northern Ireland had, and continues to have, its own separate regime for the regulation of gambling. References in this article to United Kingdom ( UK ) should therefore be read in this context. 2. The European Economic Area ( EEA ) comprises the Member States within the European Union ( EU ) plus Iceland, Liechtenstein and Norway. Why take a chance? At Dickinson Wright, we guarantee a full house of experienced gaming attorneys - more than 25 lawyers who actively represent gaming interests from strategically located offices in Washington, D.C., Toronto, Phoenix, Nashville, Detroit and Lansing. Robert W. Stocker II, Michael D. Lipton, Peter H. Ellsworth, Dennis J. Whittlesey Robert W. Stocker II and Michael D. Lipton are Tier I gaming attorneys in Chambers Global and all four lawyers pictured here are listed in Best Lawyers. We provide a full range of highly sophisticated legal services addressing the complex array of commercial gaming issues, as well as issues unique to Native American and First Nations casinos and related facilities - another reason Dickinson Wright has earned its superior international reputation. Contact: Michael D. Lipton Q.C. at Robert W. Stocker II at Dennis J. Whittlesey at Fall

9 COVER STORY Background In 1994, Microgaming 1 developed the first internet gambling software and the Caribbean s Antigua and Barbuda governments developed the first online gambling regulation (Free Trade & Processing Zone Act) 2. Thus began a continuing debate on the risks, opportunities and requirements for effective regulatory regimes for internet gambling. In the late 1990s concerns were expressed regarding increased risks for problem gambling because of the 24/7 availability, unknown product safety of online gambling 3, and embedding of gambling related marketing in regular online environments (e.g., search engines) 4. Scientific evidence indicates 5 that problem gambling rates increased in North America and Australia from the late 1980s to early 1990s, achieving peak in the late 1990s/ early 2000s. This timeframe is roughly consistent with the rapid introduction and expansion of gambling opportunities in these countries (EGMs, legal and illegal casinos, internet gambling), and increased per capita gambling expenditure and participation rates. A general downward trend worldwide in both gambling and problem gambling rates began in the late 1990s in North America, and early 2000s in Australia and other Nations. Current rates are now similar to those reported prior to 1980s gambling expansion. In Canada, the rise and fall of problem gambling prevalence has been more dramatic; likely attributable to Canada having very limited legal gambling prior to the late 1980s, in addition to the pervasive introduction of new forms. Despite decreasing problem gambling rates, internet gambling remains associated with higher levels of problem gambling. The 2010 British gambling prevalence survey 6 found that internet gamblers engaged in multiple forms compared to fewer types of gambling were more likely to be categorized as problem gamblers. Higher levels of involvement in multiple forms represented the best predictor of risk 7. Recent research in Australia 8 found that those who gambled in land-based and internet settings had the highest prevalence of gambling problems, followed by those who gambled on land-based forms alone. Those who gambled on the internet alone had the lowest prevalence of problem gambling. Structurally, internet gambling offers the capacity to effectively analyse patterns in play 9 and customer communications 10 in identifying risk and offering effective early interventions. The technological interface allows operators to offer a range of easily accessible supportive tools. The question is, how well is gambling regulation exploiting the multiple options to support players, and prevent and mitigate harm in the internet gambling environment? This article summarises a review of an International sample of regulatory requirements to identify social responsibility requirements for internet gambling. SELECTION OF STANDARDS A comprehensive search of relevant databases yielded a large number of standards, best practices, guidelines, codes and regulations the term standard is used here to encompass all of these terms. A sample of 15 key Standards were selected representing those that were up-to-date, rooted in scientific knowledge and expert opinion, drawn from new to mature internet gambling markets, and geographically diverse (Canada, Denmark, U.S.A., European Union, U.K., Jersey (Channel Islands), Alderney, and Gibraltar). These include: VOLUNTARY STANDARDS World Lottery Association s Code of Conduct concerning the use of electronic commerce for the distribution of gaming services Responsible Gambling Council s Responsible Gambling Standards Internet International Association of Gaming Regulators egambling Guidelines National Council on Problem Gambling s Internet Responsible Gaming Standards GamCare Player Protection, Code of Practice, Responsible Gambling; Remote Global Gambling Guidance Group s Responsible e-gambling Code of Practice ecommerce and Online Gaming Regulation and Assurance s ecogra Generally Accepted Practices MANDATORY STANDARDS British Columbia Gaming Policy and Enforcement Branch s Technical Gaming Standards for Internet Gaming Systems Jersey Gambling Commission s Responsible Gambling Code of Practice Applicable to egaming Operators Alderney Gambling Control Commission s Technical Standards Extract Document Gibraltar Gambling Commissioner s Code of Practice for the Gambling Industry United Kingdom Gambling Commission s Gambling Codes of Practice Fall

10 COVER STORY Spillemyndigheden s Guidelines for Betting and Online Casino U.S. State of New Jersey s New Jersey Casino Control Commission Regulation Chapter 69O Internet and Mobile Gaming VOLUNTARY WITH POTENTIAL TO BECOME MANDATORY STANDARDS European Commission s Commission Recommendation on common principles for the protection of consumers and players of online gambling services and the protection of minors from gambling combined with Commission Recommendation on common principles for responsible commercial communication of online gambling services. The two Standards, intended to complement one another, were therefore combined for analysis. Three independent reviewers identified 45 responsible gambling themes from the literature addressing some or all of the Standards. The comprehensiveness of the regulatory requirement related to each theme was evaluated on a threepoint scale based on concordance of inter-rater coding; 1 = low, 2 = moderate, and 3 = high. Higher comprehensive ratings indicated a standard with more rigorous requirements and clearer direction for implementation. Themes addressed with a high level of consensus across the majority of Standards were considered representative of current practice. For themes less commonly addressed, the researchers considered the quality of supporting evidence found in the literature. A number of less common but newer themes that were still in the early stages of evaluation but appear to be supported by extant data or have very strong face validity were considered to meet criteria as emerging practices. RESULTS The following social responsibility themes are addressed in two or more Standards. Underage Protection Of the Standards, all required age verification procedures. Three quarters included requirements for the display of warning messages and restriction of adverting/promotions targeting minors, with more than half requiring the provision of filtering software for parents to block access to sites. Player imposed limits Two-thirds to three quarters required options to allow players to voluntarily set deposit and time limits, respectively. Setting loss and bet limits were required by approximately a third of the Standards. Operator Imposed limits Although around half limited account registrations, only 10% limited the number of debit/credit card registrations. Half the Standards required cooling-off periods and a third, built-in delays restricting continuous play. Relatively (a fifth or less) few imposed the requirement to set maximums for time, loss, deposit, and bet limits. Self-Awareness Half the Standards required player information feedback on session duration, and three-quarters, current and historical expenditure. Slightly less than half required the provision of a self-assessment test for players to determine their risk or gambling status. Self-Exclusion All Standards recognised the need to include a voluntary selfexclusion policy with about three quarters specifying conditions regarding the visibility of the program for venue patrons. Around half referred to the length of exclusions and slightly less than half, reinstatement guidelines, a third temporary self-exclusion options, but less than a fifth, the option for renewal of self-exclusion agreements. Third Party Exclusion In regards to involuntary exclusion options, approximately a third recognised the need for a policy related to operator-initiated exclusion for players at risk, and third party exclusion orders. Restrictions on Site Features that may Increase Risk The majority of Standards did not address site features that could be interpreted as increasing risk for harm. Slightly over a third included policies to restrict features that encouraged players to maintain continued play, with less than a fifth and one in ten, respectively, addressed the risks of inferring that skill influenced outcomes, or encouraging play beyond affordable limits. Data Analytics Slightly less than a third of Standards required operators to use data analytics to identify at-risk players, and fewer still, less than a fifth, required operators to use data analytics as the basis to intervene in some manner to address risk. Informed Consent/Transparency The majority of Standards acknowledged the need to include policies that encourage informed choice in decision-making and transparency of game operations. This extended to requiring policies related to the access to help-related information, rules of games, and warning messages. However, less than a third required operators to clearly display odds, and one in ten required the avoidance of myths that may act to reinforce risk. Staff Training Two thirds require responsible gambling training. Some require that staff training be evaluated by a third party (NCPG), and others, that it be updated annually (G4, JGC). 10 CANADIAN GAMING LAWYER MAGAZINE

11 COVER STORY While almost all Standards require responsible advertising and promotion, few provide clear guidance on how to protect vulnerable groups such as minors and at-risk and problem gamblers. Responsible Advertising and Promotion All but one Standard required an advertising policy that must protect vulnerable groups such as minors and at-risk and problem gamblers Complaint and Inquiry Close to three quarters require operators to provide a clear complaint and inquiry submission process. For example, Procedures must exist and be easily accessible and clearly communicated to players (GamCare). Free Play Guidelines More than half of Standards address Free Play sections, requiring that operators prohibit minors, clearly communicate odds of winning and game rules, use similar payout percentages, and provide responsible gambling information (IAGR, G4, ecogra). Evaluating new games Less than a quarter of Standards require a responsible gambling evaluation process prior to the introduction of new games. Conclusion Standards vary widely in their social responsibility requirements. Across all codes, strong emphasis is placed on protection of minors, ensuring informed consent/ transparency, enabling self-exclusion, giving players information to maintain self-awareness while playing, and providing tools for players to self-manage limits on time and money. Staff training, free play guidelines and clear complaint and inquiry processes, are also addressed by the large majority of Standards. While almost all Standards require responsible advertising and promotion, few provide clear guidance on how to protect vulnerable groups such as minors and at-risk and problem gamblers. For example, in Canada there are detailed guidelines governing advertising and promotion of beverage alcohol but none exist for gambling. Emerging practices include restricting site features that may increase risk, offering third party exclusion, and a social responsibility process to evaluate new games. Advances in behavioural analysis tools have demonstrated potential for identifying risk and mitigating harm in ways that exceed what is currently possible in the land-based environment. Yet a minority of Standards address this promising practice. As with all areas of regulation, and in particular those relating to technology, a framework for socially responsible practices in internet gambling should be continually refined as new knowledge and tools become available. CGL Judith Glynn and Dr. Karen Choi are Co-Principals, Strategic Science, offering social responsibility consulting in gambling, alcohol, tobacco and obesity. Contact: Dr. Alex Blaszczynski is Professor, Clinical Psychology, and Director, University of Sydney Gambling Treatment Clinic and Chair, Responsible Gambling Research Group. Knut Walters founded Scientific Affairs, offering professional support in using high-quality scientific research for corporate affairs, public affairs and business development purposes. 1. Williams, R. J. and Wood, R. T. (2007). Internet gambling: A Comprehensive review and synthesis of the Literature. Report prepared for the Ontario Problem Gambling Research Centre, Guelph, Ontario. Aug 30, Griffiths, M. D. (1999). Gambling technologies: Prospects for problem gambling. Journal of Gambling Studies, 15(3), Griffiths, M. D., & Parke, J. (2002). The social impact of internet gambling. Social Science Computer Review, 20(3), Williams, R.J., Volberg, R.A. & Stevens, R.M.G. (2012). The population prevalence of problem gambling: Methodological influences, standardized rates, jurisdictional differences, and worldwide trends. Report prepared for the Ontario Problem Gambling Research Centre and the Ontario Ministry of Health and Long Term Care. May 8, Wardle H, Sproston K, Orford J, et al. British gambling prevalence survey 2007: National Centre for Social Research, September LaPlante, D. A., Nelson, S. E., LaBrie, R. A., and Shaffer, H. J. (2009). Disordered gambling, type of gambling and gambling involvement in the British Gambling Prevalence Survey European Journal of Public Health,21(4), doi: /eurpub/ckp Gainsbury, S., Russell, A., Wood, R., Hing, N. & Blaszczynski, A. (2014). How risky is internet gambling? A comparison of subgroups of internet gamblers based in problem gambling status. New Media & Society. DOI: / Auer, M., & Griffiths, M. (2013). Behavioral Tracking Tools, Regulation, and Corporate Social Responsibility in Online Gambling. Gaming Law Review and Economics, 17, Häfeli, J., Lischer, S., & Schwarz, J. (2011). Early detection items and responsible gambling features for online gambling. International Gambling Studies, 11, NOTE: Although not legally binding, Member States are encouraged to implement the Standards to ensure consumers and minors are protected at a similar high level in the EU. The Commission will review implementation by Member States 24 months after publication. Fall

12 FEATURE BY DEREK RAMM AML: Not Just Another Three-Letter Word Canada s gaming industry is about to face some of the most significant regulatory changes since the federal government introduced Casino Disbursement Reporting in Bill C-31, the Canadian government s omnibus budget bill, received Royal Assent on June 19, Contained within the bill were substantive amendments to the definition of casino under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act. Most notably, internet gaming that is managed by provincial lottery and gaming corporations will be subject to federal anti-money laundering (AML) and counter-terrorist financing (CTF) requirements. The coming-intoforce date has yet to be determined, but here are some of the highlights of the legislative amendments: DEFINITION OF CASINO The definition of casino under the Act has been streamlined and now only makes reference to subsections 207(1) (a) through (c) of the Criminal Code. This new definition leaves little room for interpretation as to the accountabilities for AML/CTF compliance. Essentially, there are three categories of casino : 1. Casinos that are conducted and managed in a permanent establishment by the government of a province in accordance with paragraph 207(1)(a) of the Criminal Code; 2.Casinos that are conducted and managed in a permanent establishment by a charitable organization in accordance with paragraph 207(1)(b) of the Criminal Code; and 3. Casinos that are conducted and managed by the board of a fair or exhibition in accordance with paragraph 207(1)(c) of the Criminal Code. For provinces that have engaged private sector companies to run the day-to-day operations of casinos under the management of a provincial crown corporation or agency, the new definition makes it clear that the province itself is accountable for AML/CTF compliance. INTERNET GAMING Bill C-31 further expanded the definition of casino to include internet gaming: The government of a province that, in accordance with paragraph 207(1)(a) of the Criminal Code, conducts and manages a lottery scheme, other than bingo or the sale of lottery tickets, that is accessible to the public through the Internet or other digital network. While this provision is not yet in force, the current AML/CTF customer due diligence regulatory requirements, if left unchanged, pose overwhelming operational and compliance challenges to Canada s current online gaming model. As one example, under the current regulations patrons who register for online gaming would be required to submit a notarized copy of their government identification in addition to a physical signature card. The notion of submitting physical paperwork is fundamentally contrary to the entire notion of online commerce and established practices for internet gaming. Fortunately, the federal government recognized the challenges posed by the current regulations in their December 2011 consultation paper: There is a rapidly increasing reliance on electronic means for product delivery in the financial services industry, such as through mobile phone payments in the banking sector, as well as in other sectors where services are increasingly being provided on line, such as the emergence in Canada of an on-line casino sector. Various reporting entities have identified components of the existing nonface-to-face identification requirements that limit their ability to increasingly use evolving technologies to deliver financial products and services, without requiring 12 CANADIAN GAMING LAWYER MAGAZINE

13 FEATURE an individual or entity to physically submit supporting documentation (e.g., a cleared cheque). This includes limitations with independent data sources that may currently be relied upon by credit card companies and with the requirement that a signature be provided by customers when opening an account. New regulations concerning online customer due diligence are expected later this year (and may even have been released by the time this article has been published). The regulations will also establish the coming into force dates for Bill C-31. Canada s gaming industry should assess the impact of any new regulations to internet gaming and be prepared to make representations to the federal government if necessary. DUAL REPORTING ENTITIES The new definition of casino does not clear up the issue of dual operators (reporting entities) at one casino. To gaming patrons, a casino simply looks like a casino. But in many cases the underlying legal arrangements may be far more complex. For example, a charitable organization or First Nations may operate tables games in accordance with paragraph 207(1)(b) of the Criminal Code. However, since federal law only allows a provincial government to conduct and manage electronic games, the slot machine side of the business would actually be managed by a provincial crown corporation or agency in accordance with paragraph 207(1)(a) of the Criminal Code. Are both parties accountable for compliance? What if a patron conducts transactions between operational areas on the gaming floor (i.e., tables and slots)? Who is responsible for submitting reports to FINTRAC, the federal agency responsible for enforcing compliance with the Act? These questions are not answered by the legislative amendments and will hopefully be resolved either through forthcoming regulations or guidance from FINTRAC. VIDEO LOTTERY TERMINALS Video Lottery Terminals (VLTs) are no longer specifically exempt from the Act. Establishments that have more than 50 VLTs will now be considered casinos by FINTRAC. This amendment appears to be intended to level the playing field between VLTs and slot machines across the various provincial jurisdictions. Previously, some gaming establishments were subject to the Act and others were not, depending on how provincial regulation treated electronic gaming machines. BINGO HALLS The change in the treatment of VLTs raises the question as to whether bingo halls (that is, bingo halls that do not already have slot machines) could inadvertently become casinos. The new definition of casino includes games that are operated on or through a slot machine, as defined in subsection 198(3) of the Criminal Code, or any other similar electronic gaming device. There may be some question as to whether electronic dabbers or other automated bingo machines would be considered a similar electronic gaming device under the legislation. Bingo Halls were previously exempt from AML/CTF legal requirements, so it is likely not the federal government s policy intent to subject them to the Act. Again, these questions will hopefully be resolved either through forthcoming regulations or guidance from FINTRAC. ENFORCEMENT ACTIONS If the upcoming regulatory changes aren t enough to contend with, there have been several recent high-profile enforcement actions taken against casino operators in the United States and Canada. At least two provincial lottery corporations are currently in Federal Court over administrative monetary penalties issued by FINTRAC. Last August, Sands Corporation signed a $47-million non-prosecution agreement with the U.S. Attorney s Office over alleged AML/CTF failures at their Las Vegas and Macau casinos. Two months later, Caesars Entertainment Corp. announced that their Caesars Palace casino was under a federal grand jury money laundering investigation. Whether these enforcement actions ultimately have merit, there is no doubt that federal regulators in both Canada and the U.S. are paying increasingly close attention to the gaming industry. Indeed, Jennifer Shasky Calvery, the Director of the U.S. Financial Crimes Enforcement Network (FinCEN), took direct aim at the gaming industry in a speech she gave in Las Vegas last year: When some casinos say that they are in the gaming business and not really in the business of providing financial services, I get the impression that they are saying that they should not have as much responsibility in the AML context as those financial institutions whose business it is to receive, move, and protect money. And when some casinos say that probing their customers about their activities outside of the casino will drive customers away, I sense that they feel that it is not their responsibility to protect their institutions, and our financial system as a whole, from being used by illicit actors. Where this understanding is lacking, strong enforcement efforts may be needed. When it comes to AML/CTF compliance, the gaming industry may be at a crossroads. To use a poker cliché, the industry can either rise to the occasion and go all-in, or fold and be prepared to face the harsh scrutiny of regulators, patrons and the public at large. CGL Derek Ramm is the Director of Anti-Money Laundering Programs for the Ontario Lottery and Gaming Corporation. Web links for items mention in the above article: Bill C-31 FinCEN Director Speech in Las Vegas Department of Finance December 2011 Consultation Paper Fall

14 FEATURE BY GERRY GUITOR A call for collaboration Downward pressure on revenues, digital competition threatening traditional gaming products, sizeable capital investment requirements for modernizing land-based assets and evolving IT architectures to better manage customer relationships: It s not a happy time to be in the gaming industry in Canada. Operators are struggling to rejuvenate their client-base as current products may be losing relevancy in a world of social and new gaming experiences. Increasing penetration and driving market share, growing average expenditures per visit, and enhancing loyalty to encourage repeat visits are just a few of the challenges operators are faced with in Canada. These industry-wide setbacks result in one question: How does one prepare for the future while managing short term EBITDA (earnings before interest, taxes, depreciation and amortization) challenges? CHALLENGES AHEAD Suppliers are evolving. Operators must respond. Changes across the supplier landscape could present additional challenges to the operator s growth and profitability. Recent consolidation activity in the industry (i.e. GTECH/IGT, Scientific Games Corp./Bally Technologies Inc., Aristocrat/Video Gaming Technologies) will dramatically change the supplier landscape. While this represents opportunities for operators to enhance key partnership relationships, it also represents a shift in negotiation power and the possibility of reduced innovation due to decreased competition. Initially, suppliers wading into traditional operator space, offering on-line casino environments with social gaming attributes, went without much opposition. However, a new gaming monetization scheme targeting a younger audience creates direct competition to operators and their core assets: channel ownership and customer relationship management. egaming has set a revenue sharing precedent and the door is wide open for suppliers to explore new business models and additional revenue sharing schemes. Suppliers have peaked operators interests with comprehensive player account management systems based on revenue sharing models. But these decisions may have long term financial implications as the industry moves towards distributive technology, such as cloud and server-based technology. Will these integration and product distribution solutions drive enough revenue to offset infrastructure development, increased delivery costs, and revenue sharing? Regardless, operators realize that they can t go it alone. There is a legitimate need for integration, evolution and innovation. The challenge becomes the navigation of suppliers and partners in the context of a rapidly evolving consumer demand for new gaming experiences. The cash cow that supports the coffers of provincial governments is dwindling: what can operators do in the face of dramatically evolving and challenging category dynamics? WHERE TO START? Operators should focus on two key areas: cross-jurisdictional collaboration to offset supplier advances and portfolio improvements to engage consumers throughout their gaming lifecycle. Cross-jurisdictional collaboration There are significant complimentary talents residing across the numerous gaming jurisdictions rarely shared to drive improvements, collectively. Operators need to appreciate that the real threat to their long term success is not the battle for incremental market share points but the long term viability of their category. Operators banding together to share, collaborate, innovate and drive efficiencies will lead to scale 14 CANADIAN GAMING LAWYER MAGAZINE

15 FEATURE and scope economies to ensure category renewal and long term profitability. Individual consumers may vary but high-level common interests, motivations and attitudes create alignment and a great opportunity for unified, go-to-market strategies. A collective effort must be tackled as an industry because a single operator does not have the capacity or capability to address the full scope of industry issues. To ensure the long term viability of their business model, operators need to align and collaborate on category penetration, innovation, vendor management, system management, IT investment and regulation and compliance. Managing the consumer lifecycle by optimizing the portfolio egaming is currently being managed as an additional channel where traditional gaming products and experiences are being proposed, digitally. Broader distribution benefits platform and product suppliers, IT and consulting companies but offers relatively little short-term margin upside for the operators. To truly benefit from egaming, operators need to look at the broader opportunity this channel represents: a chance to borrow from digital disruptors and evolve the gaming experience to draw in a new set of customers. Today, egaming satisfies existing customers but lays bare the incongruent nature of the younger generation s primary channel and the gaming experience being proposed. Consumers are evolving. Gaming must evolve. egaming needs to be viewed as a step in the gaming adoption ladder that can draw new gaming consumers with new gaming experiences. This does not preclude satisfying existing customers needs for convenience and mobility with traditional products. It calls for evolving the gaming experience with monetization schemes that are more familiar and acceptable to the consumer demographic. There is an opportunity to take control of gaming as a category and challenge existing thinking and commercialization principles for the digital platforms. Operators need to look at the life of the customer, from early trial to adoption to exit. Different lifecycle periods will require various product and channel strategies to ensure relevancy and adoption, increase penetration and ARPU (average revenue per unit), and drive brand loyalty. LOOKING FORWARD The commercialization model needs to change with the evolving voice of the customer. There has been much debate on the growth of egaming, social gaming s impact on the traditional gambling space, electronic or hybrid tables to offset increasing labour costs and the slow death of lotteries and land-based casinos. And while hotly debated, there has been limited insight on how operators should adapt their operational model to deal with the evolving consumer. There has been enormous focus on the young consumer to renew a client base and generate revenue, but this attention may be slightly unbalanced. Traditional casinos have a long and prosperous future. The challenge will be to target the land-based casino experience at the right consumer, with the right products, at the right moment: when the consumer s psychological, social, economic, and demographic conditions are right. egaming can play a role in preparing the ground work for category and brand adoption while a commitment to innovation can prepare the land-based assets for future demographic waves. On-line and social gaming offers a cost effective way to reach a younger demographic while enabling physical asset improvement for an older demographic. As we look at the consumer lifecycle, various lines of business could play different but supporting roles in engaging the consumer. It is important to understand the consumer shopping journey and motivations to ensure that the value chain consistently and effectively delivers against the evolving voice of the consumer. Understand and integrate Gaming delivers against needs for intensity, socialization, transformation, escapism, and pleasure. These consumer needs are greatly influenced by socio-demographic conditions and vary by consumer segment. Socio-economic conditions which are highly correlated with demographics will greatly influence gaming interaction and the type of gaming consumers adopt. Operators need to ensure that their portfolio caters to the various demographic subsets to guide the customer through the shopping and adoption journey. The gaming consumer s shopping experience can be summed up in four simple steps: visualizing, shopping and selecting, experiencing, and adopting. It is up to the operator to ensure their gaming portfolio communicates the right message to the right audience at the right time, keeping in mind the appropriate channels and touch points throughout the shopping and adoption journey. A strategic and systemic path must be created to deliver key messages and experiences that will drive customer renewal and strengthen the customer relationship ensuring long-term adoption and brand and operator loyalty. Mapping out this consumer journey and clarifying portfolio roles would be an ideal collaboration exercise for Canadian operators. Understanding, focusing, and enhancing the roles of social gaming, egaming, lotteries, casinos and bingos within the portfolio can serve every jurisdiction and is paramount for successful short term and long term EBITDA growth. An evolved egaming proposition can act as the first rung in climbing the gaming adoption ladder. CGL Gerry Guitor, a leader in PwC Canada's National Gaming Practice, is a former senior executive at a provincial gaming operator where he was responsible for commercialising casinos and egaming. Fall

16 Join IMGL in Tuscany Join the world s top gaming attorneys, regulators, compliance officers and gaming professionals this November in Florence, Italy for three days of educational programming featuring world-class speakers and special networking events. This autumn s conference also offers some additional event options including walking tours showcasing Florence s historic art and architecture, Tuscan wine-tasting and a special Saturday fashion shopping excursion. IMGL Autumn Conference 5-7 November 2014 Florence, Italy Register online at Be sure to check the IMGL website often for complete details on these events, as well as up-to-date information on the host hotel, area sightseeing, conference sessions, speakers, and more. Sponsorship opportunities are still available. For more information, contact IMGL Executive Director Melissa Triplett: gaminglawmasters.com

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